Feedback Part IV: OVDP Form 14452 Foreign Account or Asset Statement

The IRS asked for feedback on many of its current and proposed Offshore Voluntary Disclosure Program (OVDP) and Streamlined Process forms. In the video below, we describe our suggested improvements to OVDP Form 14452, Foreign Account or Asset Statement.



Below is the text of the letter we sent in support of our proposed changes to OVDP Form 14452, Foreign Account or Asset Statement:


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October 7, 2015

Internal Revenue Service
Attn: Christie Preston
Room 6129
1111 Constitution Ave. NW
Washington, DC 20224
RE: Comment from FR Doc. No: 2015-19521: Form 14452, Foreign Account or Asset Statement, OMB Number: 1545-XXXX or OMB Number: 1545-2241 (see Para. 3 below)

Dear Ms. Preston:

We are responding to the Department of the Treasury’s request for Comment on its request for OMB approval on the above-referenced form, associated with the IRS’s Offshore Voluntary Disclosure Program.

We have attempted to segregate our response into the categories of comments requested in the notice in the Federal Register.

There was an issue with this form, though. The Form 14452 that was sent to our office by Mr. R. Joseph Durbala, when we requested the versions of the forms for which approval was being sought, indicates that it was last revised January 2013 and is not the same form which is currently being used which was last revised March 2013. We have assumed that the correct version of the form for which comment is being sought is the March 2013 version currently in use.

(a) Whether the collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility:

Line 17 of the form requests “FMV at 12/31/2010 if the asset is still owned.” This date does not appear to have any relevance to the program requirements, including computation of the penalty, and there does not appear to be any other reason for the question to be asked.

(c) Ways to enhance the quality, utility, and clarity of the information to be collected:

There should be a location, most logically next to Line 1 requesting “Name of Foreign Financial Institution,” to enter the account number for the account being discussed on the Foreign Account or Asset Statement as many taxpayers have multiple accounts with the same financial institution.

We thank you for your consideration of this information and we would be happy to provide any additional information or feedback should such be needed or beneficial to this process.


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OVDP Form 14452 Presentation Slide